By David Green – Part Two


I’m fortunate to spend much of my time working with leading experts and many of the most advanced teams in the people analytics space. Based on this knowledge and experience, Figure 4 provides some recommendations with regards to the use of people data in HR analytics.

Figure 4: Recommendations on ethics in people analytics (Source: David Green, 2018)


Steps to consider here include:
Partnering with legal and IT: To ensure that you are complying with the data privacy and security legislation of the countries you are operating in as well as company rules and regulations. For example, as Patrick Coolen writes here, no people analytics project at ABN AMRO starts without approval from the bank’s legal and compliance teams nor are any findings communicated without sign-off.
Establishing a Governance Council:  To consider and prioritise potential projects is commonplace amongst the bulk of advanced people analytics teams. Ethics and privacy should be at the top of the list of items to debate by members of the council on whether to give the go-ahead to individual projects.
Publish a code of practice: To set out how you will handle employee data, which as Jonathan Ferrar suggests here is even better if you co-create the code with employees
Get ready for GDPR: Whilst ensuring compliance with the GDPR will undoubtedly cause HR and people analytics teams some pain the short-term, the legislation may provide significant benefit to the discipline in the medium- to long-term. Perhaps it’s easy for me to say this as I don’t have to implement it, but I believe that the GDPR is a good piece of legislation as it essentially forces companies to put the employee front and centre when it comes to the use of people data.

“We do not start any project without approval from legal and compliance. Furthermore we show legal our results before going to our business”
Patrick Coolen

Have an expert on your team: As Dawn Klinghoffer describes in this article make serious consideration to having a data privacy expert as part of the people analytics team (as Dawn has done at Microsoft). This is a trend I expect to see grow over the coming years.


People analytics should not be a clandestine operation where employee data is collected and analysed with the insights and resultant decisions shared amongst the chosen few. Organisations should instead be open and transparent and provide clarity to employees as to what their data will be used for and how it will benefit them as well as the company. Employees should not only be able to opt in (or out), but also be empowered through being provided access to their own data. If the insights this data provides helps employees manage their careers, improve work-life balance and increase productivity this is a clear win-win for both the worker and the company.

Two examples of this approach are:
Social Pulse, IBM’s employee listening technology helps the organisation understand  sentiment, detect problems and make a commitment to do something about them. A Case Study on Social Pulse and interview with Sadat Shami is included on page 12 of the previously referenced ‘The Grey Area: Ethical Dilemmas in HR Analytics’ white paper, and is also referred to by IBM’s CHRO Diane Gherson in this interview with Harvard Business Review. One notable example of the benefit to the employees of the technology came when an IBMer started an online petition about the company withdrawing permission for workers to use ridesharing services like Uber. This led to a storm of chatter on the corporate intranet platform. Social Pulse detected the event quickly, and Diane Gherson was able to reverse the ban and communicate the decision to employees within 24 hours.

This article by Microsoft’s CHRO Kathleen Hogan describes how Microsoft is using analytics to empower employee decision-making by creating the ability for employees to own their data,  and gain insights to help improve their engagement at work, and enhance their work/life balance.


Whilst it may be easier to adopt a risk-free approach to projects, this is not really an option for most people analytics teams if it wants to create sustainable impact. An element of bravery coupled with a close relationship with their legal team as well as a focus on employee benefit is required. Where a project involves the use of emerging data sources, pilots are a sensible option. For example, when Cisco was creating its Talent Cloud (see this article by Jill Larsen), they started with a small pilot, sought feedback from participants, iterated, communicated widely and then expanded the employee groups involved. In this way, not only did Cisco in effect co-create the Talent Cloud with employees but they also built momentum amongst the wider workforce that the product was as beneficial to employees (to support career development) as it was to Cisco (to drive strategic workforce planning).

Another terrific initiative in the realm of ethics and people analytics I became aware of last
year is being led by Insight222. The project sees member companies of Insight222’s The
People Analytics Program working together to co-create an Ethics Charter. The problem
statement Insight222 is helping clients (who include some of the most reputable brands and
advanced people analytics teams in the world) solve is: “How might HR build trust that People
Analytics work will benefit and not harm our employees, and still ensure business value and impact”.
It’s a terrific initiative and one I will watch with interest. Figure 5 below provides a high-level
view of the co-creation project. For more information, please get in touch with Ian Bailie.

Figure 5: Ethics Charter, The People Analytics Program (Source: Insight222)


The topic of ethics is as contentious as it is complex, and will continue to provoke much debate. People analytics leaders will continually be faced with the dilemma of what they could do versus what they should do. Perhaps the best test is this: if you cannot articulate the benefit to the  employee as to why their data should be collected and analysed, then the project simply shouldn’t be undertaken. There is a ‘H’ in HR after all.


The following articles and research helped inform this article: Nigel Guenole, Jonathan Ferrar
and Sheri Feinzig – The Power of People | IBM Smarter Workforce Institute – The Grey Area:
Ethical Dilemmas in HR Analytics | Deloitte University Press – 2017 Global Human Capital
Trends | Patrick Coolen – The 10 Golden Rules of People Analytics (Crowd version) | Jonathan
Ferrar – Ethics & Privacy in Workforce Analytics | Andrew Marritt – People Analytics: What’s
in it for the employees? | David Green & Dawn Klinghoffer – The HR Analytics Journey at
Microsoft | Dawn Klinghoffer – A well-balanced People Analytics function | Kathleen Hogan
– Empower your employees to leverage their own data | Harvard Business Review interview
with Diane Gherson – Co-Creating the Employee Experience at IBM | Jill Larsen – How Cisco
Is Getting to Know Each of Its 70,000 Employees | Al Adamsen – People Analytics 3.0 | Andy
Spence – The Quantified Workplace: Technology Vs. Trust


About the Author:

David Green, People Analytics Leader, Board advisor: Insight222/TrustSphere, CEO: Zandel/

David is a globally recognised and respected influencer, speaker and writer on people analytics, data-driven HR and the future of work. He has spoken at and/or chaired conferences in 25+ cities around the globe over the last 18 months including Sydney, London, Paris, Singapore, New York, San Francisco, Moscow, Las Vegas, Helsinki, Amsterdam, Lisbon and Berlin. Additionally, David also works closely with people analytics and senior HR leaders throughout the world. In combination, this imbues David with a unique perspective and insight into what’s working, what’s not, and what’s forthcoming in the field of people analytics.

David has received a number of industry accolades including winning Best Writer at the HR Tech Writers’ Awards, being included as one of 10 Power Profiles for HR by LinkedIn and is regularly included in influencer lists on people analytics, HR and the future of work. David is chairing, speaking and/or attending the following conferences between now and the end of October 2018. If you are going to one of these conferences and would like to meet up with David or you would like to book him to speak at a conference, please contact David via LinkedIn or by email on [email protected]